Draft Proceedings of the U.S. Environmental Protection Agency's Second Annual National Pollution Prevention Conference July 3O - August 2, 199O EPA Region vm Conference Center 2nd Floor - Denver Place 999 18th Street Denver, Colorado ------- Draft Proceedings of the U.S. Environmental Protection Agency's Second Annual National Pollution Prevention Conference Table of Contents Introduction 1 Agenda 3 Welcome-JerryKotas 7 Speech: Energy Technologies - Amory Lovins 8 Welcome and P2 Overview - Nancy Firestone 9 The Nature and Challenges of Pollution Prevention-Hank Schilling 11 Conference Expectations - Paul Keough 12 Session: Regional Programs/Activities 13 Session: Institutionalization/Integration 19 Action Plan Developed Speech: Coal Processes and Efficiencies - Sandy Blackstone ..22 Session: Headquarters Initiatives 24 Speech: Renewable Energy Technologies for Electricity - Robert Stokes 28 Speech: Global Warming - Richard Anthes 29 Session: Communication Among Headquarters and Regions ... 30 Action Plan Developed Session: Program Leveraging and Interfacing 33 Action Plan Developed Session: State Programs (includingTribal) 35 Action Plan Developed Session: Conference Wrap-Up 37 Executive Action Plan 40 Appendices A. Conference Attendees B. Directory of Pollution Prevention Contacts G Draft Pollution Prevention Policy Statement - January 26, 1989 D. Pollution Prevention Fact Sheets - Setting Up a Pollution Prevention Program - EPA's Pollution Prevention Incentives for States - Pollution Prevention Training and Education E. U.S. EPA Pollution Prevention Information Clearinghouse (PPIC) ------- Introduction The overall purpose of the Second Annual National Pollution Prevention Conference was to determine the pollution prevention (P2) program's next steps in implementing P2 activities nationwide. During the conference. Headquarters and Regional representatives assessed and discussed current and future efforts for institutionalizing pollution prevention practices in traditional EPA programs; developing effective internal communications; leveraging non-EPA programs to promote P2 activities in specific sectors; and promoting pollution prevention in the States and Tribes. The conference served as both an information session and as a discussion forum for Headquarters and Regional P2 managers and staff. Each Regional P2 program and several Headquarters offices (PPO, OW, OPTS, OE, ORD) reviewed the current status of their programs and/or P2 efforts and outlined future activities. In addition, the conference organizers (Regions VIII and IX) added an educational component to the conference by featuring guest speakers who lectured on energy issues. The speakers covered various topics, including renewable energy technologies, coal and energy issues, and global wanning. On a more active note, conference participants formed small discussion groups to brainstorm about promoting the institutionalization of P2 in all EPA programs and about improving communications among Headquarters and the Regions. The small groups then joined together and developed the basis for the two action plans concerning these issues. Conference participants also discussed ways to most effectively leverage other groups or activities to promote P2 and ways in which EPA can help promote State (and Tribal) P2 efforts. These discussions took place in one large group and also resulted in action plans. Thus, the conference enabled Headquarters and Regional P2 managers and staff to share their experiences and ideas in a constructive manner. Furthermore, it provided a forum in which they could establish or enhance working relationships. The tangible products of the conference include four individual action plans that describe both short- and long-term actions aimed at improving and further promoting: Institutionalization/Integration of P2 in EPA programs, Internal P2 communications, Leveraging of non-EPA programs, and State and Tribal programs. ------- For each action plan, a committee composed of Headquarters and Regional representatives was formed to take responsibility for its further development and implementation. These action plans have been developed through extensive Headquarters and Regional participation and coordination and represent a deep commitment to the P2 program and its goals. A consolidated action plan encompassing and summarizing the four individual action plans has also been developed. The action plans, summaries of conference speeches, and background and supporting materials are assembled in this final report. ------- Second Annual National Pollution Prevention Conference July 30 - August 2, 1990 EPA Region VIII Conference Canter 2nd Hoor Denver Place 999 18th Street Oenvw. Colorado Agmndm Sunday, July 29 Colorado's Rocky Mountains. Hike a mountain trail that accommodates ail levels of hiking skill. Enjoy lush meadows, aspen groves, and wild/lowers. Monday, July 30 9:30 am -11:00 am Tour of Solar Energy Research Institute (SERI) 11:00 am 2:00 pm Free Tune 2:00 pm - 3:30 pm Private Sector Panel Discussion (EPA Conference Center) Chuck Bennett, Adolph Coors Chuck Camahan, Martin Marietta Paula McLemore, American Institute for Pollution Prevention Bob McMuilen, Martin Marietta Bob Pearson, Public Service Company of Colorado 5:00 pm - 6:00 pm 6:00 pm Reception/ Registration (Embassy Suites Hotel) Dinner (Embassy Suites Hotel, Crystal Ballroom A) Complimentary Refreshments Available Welcome Jerry Kotas, Director, Pollution Prevention Division Keynote Speaker. Amory Lovins Founder and Co-Director of Rocky Mountain Institute Tuesday, July 31 8:30 am - 9:30 am Opening Remarks James Scherer, Regional Administrator, Region Welcome and P2 Overview Nancy Firestone, Special Counsel to the Deputy Administrator Pr«~eonf«r«nc« activities ( ) ar» optional ------- Evolution of Pollution Prevention Hank Schilling, Director, Office of Pollution Prevention Conference Expectations Paul Keough, Deputy Regional Administrator, Region I 9:30 am -11:45 am Session on REGIONAL ACTIVITIES Lead Moderator: Paul Keough Introduction: Why An We Here? Regional presentations highlighting activities, success stories, issues, or strategies of special interest to each Region. 11:45 am - 1.00 pm Lunch Break (On your awn) 1:00 pm - 3:00 pm Session on REGIONAL ACTTVmES (continued) 3:00 pm - 3:15 pm Break 3:15pm-4:45 pm Session on INSTTTIJTIONALIZATION/INTEGRATION Moderators John Atcheson Kevin Dick Overview Breakout into 3 discussion groups 5:15 pm Bus departs from Embassy Suites for dinner 6:00 pm Dinner (The Fort, Morrison, CO) Speaker: Sandy Blackstone Energy Minerals Economist Professor of Law at University of Denver Wednesday, August 1 8:30 am - 9:30 am Session on INSTmjTIONALlZATION/INTEGRATION (continued) Reporting to Plenary Session and Session Summary 9:30 am - 9:45 am Break « 9:45 am -11:30 am Session on HEADQUARTERS INITIATIVES Moderators: John CTOM Deborah Hanlon Jerry Kotas Hank Schilling Greg Ondich ------- Plenary Discussion 11:30am-1:00 pm 1:00 pm - 3:30 pm 3:30 pm - 3:45 pm 3:45 pm - 5:00 pm 5:00 pm Luncheon (Embassy Suites Hotel, Crystal Ballroom B) Spmkas: Robert Stokes, Deputy Director for Research Solar Energy Research Institute Dr. Richard Anthes, President University Corporation for Atmospheric Research Session on COMMUNICATIONS AMONG HEADQUARTERS AND THE REGIONS Moderators: Jerry Kotaa Betsy Shaver Overview Breakout into 3 discussion groups Reporting to Plenary Session and Session Summary Break Session on PROGRAM LEVERAGING AND INTERFACING Moderators: Jim Edwards Abby Swalne Plenary Session Dinner (On your awn) Thursday, August 2 8:30 am - 9:45 am 9:45 am-10:15 am 10:15 am-10:30 am 10:30 am-12:00 pm 12.00pm Session on STATE PROGRAMS Moderators: Jackie Krieger David Teeter Overview Plenary Session PRO'S Energy Efficiency Video: "Negawatts" Presenter: David Wann Break CONFERENCE SUMMARY: RESULTS, IMPRESSIONS, AND EXPECTATIONS Jerry Kotaa Laura Yoshii Hank Schilling Paul Keough Adjournment ------- Conference Facilitators: Lead - Paul Keough, Region I Breakout Groups - Amy Schwartz, Region 9 Jon Minkoff, Region 3 Dick Long, Region 8 Jim Dunn, Region 9 Notes: ------- Welcome Jerry Kotas Director, Pollution Prevention Division Welcome to the Second Annual National Pollution Prevention Conference, co-sponsored by Regions VIII and IX. The extensive Regional involvement with this conference is encouraging to us at Headquarters; we view it as a sign of the enthusiasm and commitment to the pollution prevention (P2) program. As the P2 program begins to grow, we need to confront a number issues, including the need to showcase our successes, increased focus on implementation (versus planning) of demonstration projects, and further enhancing our relations with other Federal agencies (energy, agriculture, commerce), and with the regulated community. ------- Speech Energy Technologies Amory Lovins Founder and Co-Director, Rocky Mountain Institute Efficient use of resources is a profitable way to prevent pollution. Energy technologies have become less expensive and are highly efficient. The United States would save three-quarters of the energy it currently uses if it were to employ the most efficient technologies. Such technologies include compact fluorescent lights, superwindows, and super-efficient cars. The profits from using these technologies arise from the reduction in maintenance and operating costs and the longer-lasting nature of these technologies (far lower replacement costs). Compared to more prevalent, but less efficient energy technologies, these newer technologies incur negative costs and thus yield profits. Although these technologies yield profits, their use has not been widespread due to several barriers. First, people do not know where to buy the newer technologies. Second, packages integrating various technologies are not readily available. Consumers generally must buy them piecemeal. Finally, there exists a payback gap. Individuals look for paybacks that are quicker and larger than the long-term payback that these technologies offer. Traditional methods to encourage the implementation of these technologies have included making loans and gifts and leasing necessary equipment. Newer methods that hold promise include holding auctions for energy, paying to save energy, selling efficiency, establishing fees/rebates on new buildings and fuel-efficient cars, and targeting and executing a massive retrofit campaign. These newer methods would essentially create a new market for efficiency. For more information on renewable technologies, write: Rising Sun Enterprises P.O. Box 586 Snowmass, CO 81654 or Rocky Mountain Institute 1739 Snowmass Creek Road Snowmass, CO 81654-9199 ------- Welcome and P2 Overview Nancy Firestone Special Counsel to the Deputy Administrator We need creativity to solve the remaining environmental problems that the Unfinished Business report describes: global warming, ozone depletion, habitat destruction, and direct exposures (hazardous waste sites, indoor air, pesticides). Pollution prevention (P2) will play a major role in solving these problems. To better understand this role and where P2 fits in the "big picture" of EPA policy and operation, we should first discuss two other concepts that the Administrator and the Deputy Administrator have promoted in the Agency: strategic planning and total quality management. Through strategic planning, we identify the most critical problems, opportunities and new approaches to address these problems, and the roles that EPA and States will play in solving the problems. Strategic planning thus enables us to direct resources to sectors and to bypass the media-specific categorizing that EPA has traditionally conducted. The Administrator and the Deputy Administrator look to total quality management (TQM) as a tool that helps to break down EPA's organizational barriers. We must tackle these barriers if we are to successfully undertake a sector-by-sector approach to critical environmental problems. For the P2 program, the strategic plan includes: identifying specific contaminants on which to focus P2 efforts; denning consistent measurable goals; identifying how to achieve reductions in contaminant use/emissions; and addressing the contaminants through sector approaches (e.g., clustering rules, targeting research, conducting technology transfer on available substitutes). Through the Toxic Release Inventory (TRI), Regions will target specific facilities that manufacture/use these contaminants and are high-risk sources. States will serve as the front line for assuring the implementation of P2 activities at these facilities. We will achieve reductions through meetings with the senior executives responsible for these facilities' operations and through vigorous enforcement and permitting. Having defined measurable goals, we will then be able to determine whether or not we have achieved what we set out to do. ------- EPA has all the tools necessary to undertake this aspect of the P2 strategic plan and to adopt a cross-media, sector approach. The barriers that we do face involve Congress and EPA's organizational structure. We are engaging in constructive dialogue with the Hill, but it will take time to get Congressional support. As for the Agency's internal structure, converting to a sector approach and reorganizing to promote inter-program collaboration must come from within in order to be most effective and acceptable to Congress. 10 ------- The Nature and Challenges of Pollution Prevention Hank Schilling Director, Office of Pollution Prevention An official definition for P2 has not been developed. Without such a definition, it may be helpful to think of P2 as the first two techniques under the following hierarchy for dealing with waste: 1. use/source reduction 2. reuse/re cycling 3. treatment 4. disposal Although use/source reduction and reuse/recycling are considered P2 techniques, reduction is preferable to recycling. In fact, including recycling in the definition of P2 has been controversial. P2 requires a broad, creative mindset. We at EPA should realize that many industries have exhibited such a. mindset and have made great strides in preventing pollution. We should foster closer relations with these industries in order to keep them going in the right direction. Within EPA, it is imperative that we take action now, while P2 is still in the spotlight, to get everyone thinking about P2 and to make P2 a part of EPA's way of doing business. We can do this by following through on the 2% set-aside projects, evaluating our grant support, and defining Headquarters and Regional roles for our next steps. 1 1 ------- Conference Expectations PaulKeough Deputy Regional Administrator, Region I In order for P2 to be successful, every person and program in EPA must think about and act to promote P2. In pursuit of this goal, we have assembled to determine the P2 program's next steps. The specific objectives of this conference are to lay the foundation for: improving communications between Headquarters and Regions; determining what roles each office/program should play; establishing a common vision of short- and long-term goals; sharing information on P2 activities throughout the Agency; and * learning more about global P2 issues. It is important that we focus on actions rather than academic issues such as definitions. To this end, the major product of this conference will be a list of action items for review by the Administrator and the Deputy Administrator. 12 ------- Session Regional Programs/Activities Abby Swaine Pollution Prevention Program, Region I Region I's 2.2 FTE for P2 are supplemented by an inter-divisional task force and by student interns. The core staff are in the Planning and Management Division. We have undertaken two major P2 efforts. First, we have established the Northeast Pollution Prevention Council, a group of 15-20 leaders in the public and private sectors. The council serves as a vehicle for promoting cultural change and education. Its members give P2 high visibility. Specific issues on which the council works include: reduction of auto emissions, CFC substitutes, and government transportation. We have run into some problems in our support of the council. For example, supporting the council is extremely time-consuming. Members do not spend time outside of council meetings working on issues. They also hold highly divergent 'views; thus it is difficult to foster consensus. Our second major effort is the development of our P2 strategy. The task force disseminated and communicated our P2 goals to the rest of the Region. We also developed a tracking/reporting system that outlines the steps (with corresponding completion dates) needed to achieve our objectives. Progress reports will be included in the Deputy Regional Administrator's quarterly reviews. As the P2 program matures, we wish to take a longer-term view in the strategy and streamline its objectives. Palma Rlsler Office of Policy and Management, Region II Region II does not have any official FTEs devoted to P2 work. We do have an advisory group composed of deputy division directors, but no staff workgroup exists. Because we do not have any 2% set-aside projects. Region II's P2 program has an in-house credibility problem. Attempts to integrate P2 into current activities have had mixed results, largely due to inadequate communications. 13 ------- We are currently working on a number of initiatives, including development of a waste reduction statement; development of a a checklist for site visits; targeting largest emitters with TRI; and development of P2 guidance that includes industry-specific techniques. In order to expand the P2 efforts in Region II, we need to establish a staff workgroup, conduct more extensive training, incorporate P2 into strategic planning, and take steps to promote P2 in industrial development activities. Nancy Grundahl Environmental Services Division, Region III In FY90, Region III has 3.0 FTE dedicated to P2 work in addition to a policy team and a staff workgroup. We have benefited from extensive involvement by the Deputy Regional Administrator. Internal efforts have focused on training inspectors, RCRA permit writers, procurement of recycled goods, targeting with TRI data and GIS, encouraging use of mass transit, and displaying P2 messages on in-house video monitors. Other efforts include business, public, and consumer outreach through EPA speakers. In one of our success stories, using TRI data, we traced ground-water contamination to IBM which agreed to phase out the sources of contamination. Betsy Shaver Office of Policy and Management, Region IV The Region IV P2 program enjoys strong support from the Regional Administrator. Primary responsibility for the P2 program resides in the Office of Policy and Management which coordinates all new P2 initiatives that have not been institutionalized into the program offices. We have 1.0 FTE dedicated to P2 work. Our outreach efforts have included enhancing the Waste Reduction Resource Center to conduct more on-site work to assist State waste reduction programs. We also train retired waste reduction assessors to conduct waste reduction opportunity assessments. "Inreach" efforts include: 14 ------- basic P2 training and orientation for all employees; inspector training; P2 incorporation into enforcement settlements; new source review; in-house recycling program; and procurement of recycled goods. Glass Planning and Management Division, Region V In Region V, we have a core staff of 0.7 FTE under the supervision of the Planning and Management Division. In addition, we are forming a P2 workgroup to oversee our five P2 grants and two 2% set-aside grants. Region V is historically enforcement-based; it is slowly accepting the concept of P2. Some of our projects include developing a P2 strategy for the Great Lakes, conducting P2 efforts in RCRA (training, permits, use of TRI, advisory group for waste management), and assisting a Milwaukee sewage district with its efforts to meet permit limits and identify risks. Lynda Carroll Office of Planning and Analysis, Region VI Region VTs P2 efforts began in March 1989 i We have 0.7 FTE of core P2 staff, a steering committee of senior staff, and a staff workgroup. The Office of Planning and Analysis coordinates all of their efforts. We are pursuing a number of P2 activities, including: * a joint venture with the University of Texas/Arlington (UTA) to develop a network connecting UTA, EPA, businesses, industries. State and Federal regulatory agencies, and other universities, thereby facilitating research, technical assistance, and dissemination of environmental knowledge; an aggressive recycling effort for Federal offices; working with the Mexican government to collect air quality monitoring, meteorological, and emissions inventory data; an evaluation of toxic pollutant releases from industrial plants; outreach efforts to the media and the regulated industries; and settlements with P2 provisions. 15 ------- In order to improve the Regional P2 program, we need to involve representatives from all the program offices and to establish better communication with our States. Alan Wehmeyer Waste Management Division, Region VII Within Region VII, the Deputy Regional Administrator has lead responsibility for P2 efforts, and I serve as the Regional P2 coordinator. A P2 advisory council of senior staff members provides the vehicle for P2 communication throughout the Region. We do not have any FTEs dedicated solely to P2 work; divisions simply give up workyears. The Region has a large number of P2 projects are underway. They include efforts to: develop educational materials suitable for kindergarten through twelfth grade; develop P2 technology with small quantity generator industry groups; reduce loading of agchemicals into two'surface water impoundments; implement procurement guidelines; develop a corporate guide to pollution prevention with Hallmark Cards; conduct outreach with other Federal agencies to initiate office recycling programs, develop waste reduction strategies, and procure recycled paper and paper products; and use TRI data to target prevention opportunities. Don Patton Policy and Planning Office, Region VIII The Assistant Regional Administrator has lead responsibility for Region VIII's P2 activities. A steering committee composed of deputy division directors provides guidance for our efforts. Our core P2 staff consists of 0.5 FTE. Our ongoing P2 projects include: establishing a non-profit environmental alliance with Martin Marietta, Coors, Hewlett-Packard, and the Public Service Company of Colorado to work on reducing solvents and increasing water and energy conservation; 16 ------- funding 28 teachers to attend P2 presentations by all program offices, consultants, and academics; creating a used oil recycling center in conjunction with the public-private partnership people; and developing a cooperative Governmental/Private Multi-Media Strategy of on-farm applied research and demonstration of sustainable agricultural practices. Laura Yoshii Hazardous Waste Management Division, Region IX A steering committee chaired by the Deputy Regional Administrator and composed of office directors and their deputies provides policy guidance for Region DCs P2 efforts. A core P2 staff (3.0 FTE in FY91) carries out P2 activities under my supervision. Accountability measures for our efforts do exist. The steering committee receives status reports on P2 activities at their monthly meetings. In addition, P2 activities are outlined in operating plans and assessed in DRA quarterly reviews. We are currently working on various projects to: conduct hazardous waste minimization workshops for auto repair shops, labs, etc. in conjunction with a county government; assist local governments in training inspectors to do waste minimization assessments; reduce metals loadings from POTWs through modification of permits, workshops, videos, and development of waste minimization programs; incorporate P2 into enforcement settlements and waste incineration permits; publish P2 brochures for UIC Class V wells; conduct educational outreach on TRI data; publish a quarterly newsletter for Regional staff; establish an in-house recycling program; and enhance the collection of in-house P2 resources. In the future, we intend to invest FTE more heavily outside of the core P2 staff. 17 ------- David Teeter Hazardous Waste Division, Region X The P2 program in Region X consists of 1.5 FTE of core staff, a staff workgroup, a steering committee comprised of division directors and senior staff, and overall supervision from the Planning and Management Division. Region X's activities had been slowed by the lack of a Regional and Deputy Regional Administrator. Currently, our priorities are to: build P2 into traditional programs; establish a strong EPA/State relationship in P2 activities; make greater use of data management tools; and establish a means of measuring progress. P2 projects underway include establishment of a Northwest P2 resource center, a recycling effort during the goodwill games, establishment of an in-house recycling program, placement of recycling bins in ferries, development of compliance/enforcement tools to promote P2 in negotiations, and investigation of recycling in Federal facilities. 18 ------- Session Institutionalization/Integration Institutionalization or integration refers to the process of making P2 a part of every EPA employee's responsibilities and every program's activities, and includes improving coordination between programs to address multi-media issues. Since few additional resources are available, in order to enhance the effectiveness of our existing programs it is crucial that P2 become integrated into all of EPA's existing program activities. Effective institutionalization of pollution prevention in the Regions has stemmed from senior management involvement in establishing expectations and accountability. As a the result managers and staff are willing to adopt pollution prevention, and make Regional disinvestments which redirect resources to support pollution prevention. To date, many P2 activities have been initiated within Regional program offices. These activities have resulted from Regional initiatives brought about through the Regional P2 pilot projects as well as through the set-aside projects and other cooperative efforts. Common elements of achievements in institutionalizing P2 in the Regions include: upper management (RA/DRA) involvement in establishing expectations and accountability {i.e. through the quarterly review process) and Regional disinvestments which redirect resources to support pollution prevention. Although HQ program offices are beginning to become involved in some of the sectorial P2 initiatives, it is a common perception that efforts to institutionalize P2 within the HQ program offices have achieved limited success. Barriers to institutionalizing P2 include: turf; inertia; lack of an established definition, clear expectations, and accountability; and workload constraints. The following recommendations are offered as suggestions to more effectively promote institutionalization of P2 within EPA. 19 ------- ACTION PLAN L Short-Term Actions Education/Training Require P2 training of all EPA employees. Priority Setting Immediately and clearly define P2 in a final P2 Policy Statement. Establish a framework for identifying priority areas for P2 considering: P2 experience and accomplishments to date; Opportunity; Risk; Coverage (i.e. toxics, MSW, energy, agriculture); and Cost Establish a schedule and process for priority area identification. Translation of Priorities into Action Establish specific targets, goals, and expectations; include initial targets, goals, and expectations in the P2 strategy; and make the P2 strategy an Agency-wide strategy rather than an OPPE strategy. Establish means of accountability and reward for P2 approaches; involve Administrator or Deputy Administrator in Advisory Committee process; and develop model language and incorporate in performance standards to sponsor upper- and mid-level management support of P2. Include P2 explicitly in STARS targeting and reporting requirements. Assure that budgets and resources are initially flexible enough to support P2 activities, and ultimately reallocate resources to allow P2; include P2 in all NPM program elements and workload models; and require an established level of disinvestment and redirection of resources within program offices to support institutionalization of P2. 20 ------- Build P2 more explicitly into strategic planning and comparative risk activities; and involve P2 staff in strategic planning preparations. Assure that implicit P2 opportunities in new statutes and programs are fully utilized (i.e. Clean Air Act Amendments when passed, expanded FY 91 Subtitle D program). Facilitate the integration of P2 enforcement and permitting by clarifying Agency authorities in these areas and compiling model and actual P2 enforcement (including settlements and credits) and permitting provisions and requirements. Long-Term Actions Involve/reorient other Federal agencies (i.e. DOD, DOE, USD A, DOI, Commerce, DOT, etc.) to better undertake P2 through: cooperative efforts, and Executive Orders/legislation. Develop enforcement focus on enhancing compliance, in addition to punishing non-compliance: Encourage auditing; Use inspectors; Develop initiatives in high-risk industries; and Match training and technical assistance with areas needing special attention. Assess regulatory and statutory mandates for P2; and implement pilot projects pursuing multi-media P2 and organizational integration. Restructure the budget process to support P2. 21 ------- Speech Coal Processes and Efficiency Sandy Blackstone Professor of Law University of Denver Political, legal, regulatory, and institutional issues have heavily influenced coal processes and their effects on the environment, often forcing industry to undertake inefficient processes and making it impossible or infeasible for the coal industry to adopt approaches designed to prevent, rather than control, pollution. This has been evident in each phase of coal production and use, from coal mining and transportation to generation and transmission of electricity. In the area of coal production, certain regulatory and tax policies have favored underground coal mining in the East -- a process that involves more danger (in terms of human lives lost) and environmental damages (subsidence and acid mine drainage) than surface mining, primarily a western production process. In the 1970's, the Congressional mandate for scrubbers in all new coal-fired power plants served not only to eliminate the lower costs associated with producing western coal, but also to incur enormous energy costs, reduce energy efficiency, and increase CO2 emissions and solid waste disposal problems. Legal and institutional constraints have also prevented the coal industry from using coal slurry pipelines, an efficient means of transporting coal. Of all the phases of coal production and use, the coal conversion phase has the greatest potential for achieving increased energy efficiency. Because of their improved efficiencies, "clean coal" technologies (e.g.. integrated coal gasification combined cycle system) can reduce acid rain-type pollutants and CO2 emissions. Such technologies have been demonstrated and can soon be used in commercial applications; however, barriers to their use include conflicts among State public utility commissions and lack of financial incentives for the capital investments necessary. We need to encourage the use of clean coal technologies. If we rush to respond to concerns about acid rain and global warming, we force industry to use existing technologies that have higher costs and that result in greater pollution. Several aspects of the pending Clean Air Act amendments appear favorable to clean coal technologies (e.g., emission allowances, emission trading), but schedules for implementing these measures should allow for the integration of clean technologies in new plants and the retrofitting of existing plants. 22 ------- Alternative means of reducing CO2 emissions globally are not as feasible. CO2 scrubbing (removing CO2 from stack gases) is costly and would require approximately 15% of power plant capacity. Using natural gas or renewable technologies has limited global potential due to economic and technical barriers. Finally, the efficient transmission of electricity from surplus supplies to areas with excess demand has been hampered by jurisdictional conflicts among Federal, State, and local agencies. Thus, the major obstacles to employing pollution prevention in the coal industry are not technical and economic, but political and institutional. 23 ------- Session Headquarters Initiatives Hank Schilling - Legislation Director, Office of Pollution Prevention Reauthorization of the Clean Air Act has taken precedence over P2 legislation; it is unlikely that such legislation will be proposed this year. The P2 policy statement is in the draft stage. Anyone interested in obtaining a copy of the draft should see me. The next five speakers will inform you or activities in various program offices. The last three speakers from the Office of Pollution Prevention will fill you in on some of our activities. Richard Hefter Office of Pesticides and Toxic Substances The Office of Pesticide Programs (OPP) has two P2 goals: (1) restrict/eliminate pesticides causing adverse effects; and (2) encourage the development of safer pesticides. OPP will pursue these goals through pesticide registration, pesticide reregistration, review of volatile organic and other chemicals in pesticide formulations, implementation of the ground-water/pesticide strategy, and development of worker protection regulations and economic incentives. Susan Hazen Office of Toxic Substances The Office of Toxic Substances (OTS) seeks to build P2 into its TSCA responsibilities which focus on risk mitigation and have traditionally relied on command and control. OTS's P2 initiatives include: a 2% set-aside project to reduce lead exposure; support for a P2 university research center; incorporation of a P2 review of TSCA chemicals before they go on the market; substitutes for TRI chemicals; expansion of SIC codes covered by TRI reporting; inclusion of Federal facilities in TRI reporting; 24 ------- mandatory P2 questions in TRI; and revision of the Section 313 chemical list. Gregory Ondich Office of Research and Development The Office of Research and Development (ORD) published the Pollution Prevention Research Plan (Report to Congress) in March 1990. The plan targets hazardous wastes, municipal solid wastes. pesticides, stratospheric ozone depletion/global climate warming, indoor air pollution, and consumer products. Within these areas, ORD places greater emphasis on product research, socioeconomic and institutional research, and technology transfer efforts. ORD also provides support for the Pollution Prevention Information Clearinghouse (PPIC) and the American Institute for Pollution Prevention (AIPP), an advocacy group composed of officials from industry, academia, professional societies, and government. Vivian Daub, Deborah Gillette Office of Water P2 efforts are not new to the Office of Water (OW). OW has already established non-point source, wellhead protection, and effluent guidelines programs that focus on P2. Newer P2 initiatives within OW include: reviewing P2 legislation; developing strategic plans; taking the lead on agricultural sector workgroup; promoting P2 in effluent guidelines; developing NPDES permit writer training courses that incorporate P2 concepts; and examining the reuse of sludge. Cheryl Wasserman Office of Enforcement Enforcement is an important component to the prevention of pollution. Liability, public disclosure, and the threat of penalty forces the regulated community's attention to P2. 25 ------- The Office of Enforcement's (OE's) P2 strategy involves enhancing ongoing outreach in environmental auditing and environmental management; developing policy on the incorporation of P2 in settlement conditions; targeting based on risk and P2 opportunities; using compliance inspectors to disseminate information; using the National Environmental Policy Act and the Federal Agency Roundtable to promote P2; promoting P2 on Indian lands; and promoting P2 in the annual budget process. OE has already developed an interim policy on enforcement settlements and a system for evaluating such settlements. Peter Rosenberg has responsibility for the development of this policy. Please send him case examples in which you have incorporated P2 into enforcement settlements. John Cross - Authorities, 2% Projects, Resources Office of Pollution Prevention The Office of Pollution Prevention (PPO) is examining existing statutes to determine which ones accommodate P2 efforts. A general statement citing these authorities will be incorporated into the P2 strategy. Approximately 60 to 75 percent of the 2% set-aside projects are progressing. The remaining projects await clearer definition. PPO has sought clarification from the Office of the Comptroller on the logistics of getting the resources for the 2% projects to the program offices. In FY91, the budget for 2% set-aside projects may be cut; however, it is uncertain as to how large the cut would be. The overall FY91 budget allocates approximately $1.1 million for Regional activities ($30,000 per Region). An additional $3.0 million will be available for grants. No Congressional add-on is expected. Deborah Hanlon - Training Office of Pollution Prevention Training is critical in order to integrate P2 into the EPA "corporate" culture. PPO has formed a training subcommittee of the EPA Pollution Prevention Advisory Committee. The training subcommittee will assist in implementing EPA's P2 training strategy, identifying training needs and resources, establishing criteria for P2 programs, developing training tools for use by Agency, State, and industrial personnel, and communicating existing P2 training opportunities to other EPA offices and Regions. 26 ------- The training strategy that PPO and the training subcommittee have developed and will implement consists of four phases: (1) "generic" P2 training workshop for EPA, State, and local government personnel; (2) PPIC and PIES hands-on training; (3) industrial pollution prevention workshops; and (4) permits, enforcement, and other industry-specific workshops. Jerry Kotas - PPO Overview Office of Pollution Prevention We are making progress in promoting P2 throughout the Agency. As we work to further support P2 efforts, we need to focus on effecting transformational change change from within. The Pollution Prevention Division's numerous activities are carried out by 19 people who field approximately 300 calls per day. As such, we are spread thin and need to determine how to target our efforts most effectively while continuing our service orientation. In addition, we need to balance our long-term and short-term efforts. Besides those projects that you have heard about from other speakers,. the division has responsibility for a large number of other projects, including: targeting rules and clusters of rules for P2 efforts; targeting specific chemicals for P2 efforts; developing the P2 strategy; assisting other programs with their strategic plans; establishing Headquarters desk officers; leveraging outside groups (e.g., SAB, AIChE); developing and distributing a P2 newsletter; and supporting international efforts with OECD, UNEP. 27 ------- Speech Renewable Energy Technologies for Electricity Robert Stokes Deputy Director for Research Solar Energy Research Institute Natural, renewable energy resources -- sunlight, wind, trees, plants, rivers, and hot springs provide approximately nine percent of our domestic energy, supplying electricity, heat, gaseous fuels, and liquid transportation fuels for homes, cars, and industries. Renewable energy technologies for electricity include: Hydropower Biomass combustion of wood, agricultural wastes, municipal solid wastes, and gases generated by landfills Geothermal Energy Wind Machines Solar Thermal Power Plants Photovoltaics -- conversion of sunlight directly to electricity using solid-state technology Electricity from renewable energy systems is cost-competitive, ranging from five to ten cents per kilowatt-hour. The costs associated with most of the technologies listed above will decrease in the future as the technologies mature. In addition, the modular nature of renewable energy systems allow utilities to add capacity in step with demand, without long lead times or major capital investments. Thus, using renewable energy makes good economic sense. It makes good environmental sense as well. Using renewable energy rather than fossil fuels can help utilities to reduce their carbon dioxide emissions. 28 ------- Speech Global Warming Richard Anthes President University Corporation for Atmospheric Research The year 1988 was the warmest year on record in the Northern Hemisphere. Severe droughts plagued much of the world, while floods devastated other regions. Hurricane Gilbert, the strongest Atlantic hurricane on record, caused massive property damage in El Salvador. In its January 1989 issue, TIME Magazine named the endangered Earth "Planet of the Year". The events of 1988 do not prove that the Earth is warming up due to an enhanced greenhouse effect associated with a rapid increase in "greenhouse" gases such as carbon dioxide, methane, and chlorofluorocarbons, but they are consistent with changing weather and climate patterns that many scientists believe is possible, or even likely, in the decades ahead. Many scientists believe, in fact, that the earth is headed for a climate warmer than ever before experienced by human civilization. My talk reviews what is currently known about the changing atmosphere and what is currently known about the likely climate changes in the future. We know without a doubt that radioatively active greenhouse gases are increasing; for example, the carbon dioxide in the atmosphere has increased by nearly 15% in the last 30 years and at a 1990 concentration of 353 ppmv is now higher than at any time in the last 160,000 years. Climate models indicate that this increase, plus the increase in other greenhouse gases, is likely to cause an increase in global mean surface temperature by between 1.5 °C and 4 °C in the next 50 years. The increase in greenhouse gases is being caused by an unprecedented growth in human population. The doubling time for the world population has decreased from 1,500 years in 8000 B.C. to less than 35 years at present. The exponential growth in human population and the activities of this population are the fundamental causes of the increasing greenhouse gases. They are also responsible for other assaults on the environment such as the deforestation of tropical regions and the decrease in the Earth's protective ozone layer. Thus the solution to global atmospheric pollution and environmental destruction must include a stabilization of the world's population. 29 ------- Session Communications among Headquarters and Regions Effective communications among all parties in the pollution prevention program are critical to its success. Only after internal P2 program communications are effectively established can the program coordinate its efforts successfully with other Agency programs and with organizations external to EPA. The Headquarters P2 program has the responsibility to focus its communications in order to provide leadership, direction, and financial, legal, technical, administrative, and policy support. The core P2 personnel in the Regions must be informed of Headquarters and other Regional activities in order to credibly and effectively promote and carry out the program and to take advantage of other efforts so as not to "reinvent the wheel". Communications should serve the following purposes: Promote the development of a consistent, yet creative and innovative program by the Regions and Headquarters; Eliminate/reduce duplication of efforts; Reduce conflict and omission; Provide.cross-fertilization of ideas; Support effective resource allocation and use; and Provide information, guidance, and cooperation. The following action plan, developed by conference participants, identifies specific items that will assist in improving communications among Headquarters and Regions to serve these purposes. Responsibility for the items are indicated in parentheses ( ). ACTION PLAN L Short-Term Actions Telephone Calls Give Regional contact calls higher priority (HQ) Provide more information in messages left for a HQ response (Regions) Obtain necessary telecommunications tools/services (i.e., proper cabling, phone service, E-mail) (HQ) 30 ------- Conference Calls Schedule conference calls on a regular basis (HQ) Focus calls on a topical subject (HQ/Lead Region) Provide information to be discussed prior to conference call (HQ) Review and Comment of Documents Include Regions in review of all policy-related documents (HQ/Lead Region) Focus Regional review through lead Region (HQ/Lead Region) Allow adequate time for review; inform Regions of upcoming review schedules so as to effect better planning (HQ) Reports Send Regions draft bi-weekly reports (HQ) Send HQ quarterly management memos and/or more frequent reports that are currently prepared by Regions (Regions) Send weekly "care packages" to Regions (HQ) Newsletter Retain; it is a good mechanism EL Medium- to Long-Term Actions (May Require Study or Changed Procedures) Telephone Calls Funnel calls (from Regions) to the Regional contact(s) more effectively; requires determining who and how many Regional contacts there are (HQ/Regions) Establish Directory for P2, including organization, telephone, and electronic mail numbers and functional/activity lead responsibility of all P2 staff in HQ OPPE, ORD, the programs, and likewise in the Regions/labs (HQ/Lead Region) Investigate the use, but not abuse, of voice mail to ease the telephone answering crunch (HQ/Regions) Conference Calls Involve Regions more and in a more timely way in agenda formulation (HQ/Lead Region) Clearinghouse Include more Regional materials: Define what these materials are; Determine a mechanism to write the materials up; and Determine how to include them in the Clearinghouse (Regions/Clearinghouse/HQ) 3 1 ------- Use the Clearinghouse more fully Determine how to do this (All/Clearinghouse) Include more HQ materials (HQ/Clearinghouse) Lead Region Enhance the role of the Lead Region in coordinating communication between Regions and HQ on: policy/regulations, operating procedures and processes, budget, resource allocation roles, etc. (Lead Region/Regions/HQ) Review and Comment Define role of Regions in shaping policy (HQ/Lead Region) Meetings Arrange more frequent meetings (HQ/Lead Region) Focus meetings for smaller groups and single topics (HQ/Lead Region) Reports Write and submit reports on projects when they start and end in a case study or profile format (HQ/Regions) Newsletter Include more Regional information (HQ/Regions) E-Mail Look into more use of E-Mail (HQ/Regions) DRAs Determine what information they need (Regions) Send them P2 information in brief form with high HQ signature (HQ) HQ Desk Officers Define and enhance desk officer system to provide better service to the Regions (HQ) 32 ------- Session Program Leveraging and Interfacing The pollution prevention program has intensified its efforts to educate other EPA programs and Federal agencies about pollution prevention, and to pursue joint pollution prevention initiatives with these programs and agencies. Within EPA, the pollution prevention program has begun to work with Public/Private Partnerships, Technology Transfer. Strategic Planning, Comparative Risk, and Enforcement Credits to infuse these programs with the pollution prevention ethic. Outside EPA, the pollution prevention program has begun to develop policies and projects with the Departments of Defense, Energy and Agriculture. Finally, the pollution prevention program is communicating with national associations and groups whose efforts can further the goals of the pollution prevention program. However, the pollution prevention program's efforts to work with other EPA programs. Federal agencies and other groups are currently hampered by a perceived lack of "clout" behind pollution prevention within EPA. For the pollution prevention program to be able to market its concept effectively and leverage outside resources, it must be able to demonstrate that it has a coherent identity, institutional recognition and resources. The pollution prevention policy statement and agency- wide strategy will make great strides in establishing a creditable identity. However, most specific policies (permit writing, enforcement credit projects, inspections, etc.) are still far from completion. Upper management buy-in and earmarked resources for pollution prevention within other programs would increase institutional recognition. Increased resources would enable the pollution prevention program to more aggressively pursue agreements with other EPA programs, Federal agencies and outside groups. Given the limited resources available currently, the pollution prevention program is concentrating its efforts on the following: 33 ------- ACTION PLAN Short-Term Actions Use fully environmental audit capabilities and mechanisms, including manuals, protocols, and training workshops that have been developed by HQ. Keep Regions abreast of DOD, DOE, and other Federal activities so as to facilitate Regional participation in inter-Agency initiatives. n. Long-Term Actions Within EPA, focus on leveraging strategic planning, technology transfer, comparative risk, and public-private partnership efforts efforts that are most receptive to and supportive of P2 and that have high potential for "symbiotic" relationships. Work with the new Office of Environmental Education to promote P2. Target leveraging efforts outside EPA to those Federal agencies (DOD, DOE, DOI, USDA) and groups that have significant P2 opportunities. Leverage training with industry, universities, and businesses. 34 ------- Session State Programs (including Tribal) Currently, a number of States have dynamic or evolving programs that can point to significant pollution prevention achievements. In fact. many States are at the forefront of pollution prevention implementation. Other State programs, however, are only beginning and are not yet fully operational. Many States have no recognizable pollution prevention program or are hampered by the media-specific nature of their environmental organizations. State pollution prevention prevention programs also vary as to their focus (single or cross-media) and their level of funding. The Pollution Prevention Division in Headquarters has awarded 53 grants to 37 States. Most of these grants have been awarded to State regulatory and environmental health agencies. In FY 91. approximately $5.0 million will be available to States, Tribes, and inner-state agencies. For EPA, there exist two important questions concerning state pollution prevention programs. First, what can EPA do, besides award grants, to promote and support State and Tribal pollution prevention programs? Second, how should grants programs be designed and implemented to best promote State and Tribal pollution prevention programs? The following action plan identifies specific items that can help to answer these questions. ACTION PLAN L Short-Term Actions Promote/Develop State and Tribal Programs Identify and focus on areas where States can be helped most: Program implementation activities; Technical assistance; and Grant application preparation. Identify and take advantage of other tools which can help to improve State programs: State/EPA Agreement preparation meetings and reviews Other Grants: RCRA, Superfund; State Minimization Roundtable; Clearly stated expectations in a policy/strategy statement; and 35 ------- Training. Create incentives/credits for State implementation of P2. Grants Management Create a HQ/Region workgroup that will work to improve, clarify, and communicate the process for (1) determining program objectives/ direction/criteria which specifically support P2; (2) determining HQ/Region roles; (3) targeting and awarding State grants and (4) expediting the transition of the grant program (i.e., allocation of resources, administration, and management) to the Regions. Inform Headquarters if interested in taking over grants management (Regions). (Grants management includes receiving/reviewing semi-annual reports, providing technical assistance, conducting on-site visits, and conducting informal communications.) n. Long-Term Actions Develop response to the Appropriation Committee's proposal to change P2 grants into a 50-50 matching grant program. Transfer management of the program to ROs, with policy and guidance from HQ (traditional EPA roles). 36 ------- Session Conference Wrap-up PaulKeough Deputy Regional Administrator, Region I We have discussed institutionalization/integration, communication, leveraging/interfacing, and State programs, and we have appointed groups to analyze each of these issues and recommend how to overcome some of the barriers identified during the conference. I think it is important for senior Agency management to know what progress the P2 program has made. To this end, Region I, as lead Region, will be responsible for getting together a package to be presented to the Administrator, the Deputy Administrator, the Deputy Assistant Administrator for OPPE, and all the Regional and Deputy Regional Administrators. This package will contain a brief overview of the conference, summaries and action plans for each of the four sessions, and a one to two page summary from each Region and from each Headquarters program on major success stories. In addition, we will invite the Administrator to the next Pollution Prevention Advisory Committee meeting. Hank and I will give him a brief summary of what has happened and is happening in the P2 program. We would like to bring in some of the Regional P2 people to brief the Administrator on several of their promising projects. It is extremely important to keep up the momentum, especially given the uncertain budget situation. We need to show that for a small investment, P2 achieves significant accomplishments. Because what we do as follow-up determines how truly successful this conference is, I propose that in the next six months a smaller group convene and assess how far the P2 program has progressed. The six month timeframe is crucial; I do not think it is wise to wait a whole year before assessing our progress. This smaller group can then use their assessments to develop an agenda for the next national meeting. Laura Yoshii Deputy Director, Waste Management Division, Region IX Upon reflection, one of the most outstanding features of this conference and the P2 program is the quality of the people. This is a bright, committed, energetic, action-oriented group. Attending this conference has revitalized me and my thinking about the changes 37 ------- needed in the Agency. Seeing so many talented people has made me confident that such changes will happen. Paul's plan for "advertising" the P2 program is a good one; it will help us gain recognition for the important activities that we have undertaken. From Nancy Firestone's presentation and several of the sessions, it became clear to me that there are several areas that we need to focus on. First, we need to tie together strategic plans and comparative risk studies so that we can better coordinate all of our activities. Second, we need to learn more about total quality management and how it will help us change our way of doing business for the better. Third, we need to take fuller advantage of the clearinghouse. Finally, we need to work on leveraging other Agency programs and breaking down the organizational barriers. Jerry Kotas Director, Pollution Prevention Division I would like to stress the importance of keeping senior Agency management informed of our progress. Paul has emphasized this, and I agree with his plan. As Nancy Firestone and others pointed out, it is necessary to balance specific short-term targets that can achieve tangible successes with medium- and long-term goals (e.g., moving towards a sector focus). It will be a difficult balancing act in which leveraging will be the key to success. Of course, we do need senior management support to leverage successfully. I recommend that each Region and each office in Headquarters establish a negawatt expert familiar with the types of technologies that Amory Lovins presented. What the P2 program is doing is not easy; we are trying to change the Agency's traditional way of doing business. To accomplish this, we have to keep working together. Hank Schilling Director, Office of Pollution Prevention In the past three days, we have voiced differing views, but have managed to keep the conference positive and productive. Thus, I am 38 ------- filled with ideas and insights. A follow-up document describing what we have done will help to turn all of our ideas into concrete actions. If you wish to see the current draft policy statement, let me know. I am especially interested in hearing about any conceptual errors you may find. Thanks to everyone. 39 ------- Executive Action Flan As lead Deputy Regional Administrator for the Office of Policy, Planning and Evaluation, Paul Keough chaired the P2 Conference and compiled the following Executive Action Plan which was presented to the Administrator. These action items along with the individual session plans constitute the overall Action Plan from the conference. I. POLICY ACTION ITEMS The Proposed Pollution Prevention Policy Statement has not yet been finalized, leading to confusion in EPA, industry. States and the public as to what constitutes pollution prevention. ACTION OPPE should release a final pollution prevention policy statement which clearly and concisely defines pollution prevention by October 1, 1990. Pollution prevention can have a beneficial impact in all sectors of society. It is important to maintain efforts in various sectors so that pollution prevention does not become associated only with toxics, or only with particular chemicals. The planned pollution prevention strategy should develop a framework the ability to build on pollution prevention experience and accomplishments, existing program opportunities, risk, cost, and technical feasibility. ACTION Charge the Pollution Prevention Advisory Committee with identifying a broad range of pollution prevention target areas by November 1990. The proposed pollution prevention policy statement broadly defines source reduction and recycling as pollution prevention. Lack of explicitly defined actions and expectations of Federal. State and local programs has hampered progress in these areas. ACTION The Pollution Prevention Advisory Committee should develop specific targets, goals, and expectations, and communicate them nationally through the Strategy, and through all of our programs. 40 ------- Few programs and statutes (i.e. Clean Air Act Amendments, FY '91 RCRA Subtitle D Program, strategic planning, comparative risk. Total Quality Management) offer a unique opportunity to design pollution prevention right into regulations and operating procedures rather than later conducting a "retrofit". ACTION The advisory Committee, working with appropriate senior managers should insure that implementation efforts for new programs should incorporate pollution prevention activities. H. MANAGEMENT SYSTEM ACTION ITEMS Few managers have used their flexibility to commit resources to support pollution prevention activities within their programs, and it is unclear what workload model tradeoffs may realistically occur. Most of the Regions have achieved initial success through unofficial, marginal disinvestments within their programs and redirecting FTE to support pollution prevention. ACTION HQ program offices should receive clear direction from the Administrator to redirect some portion of workload model FTEs to support Regional pollution prevention activities in their program area. The level of FTE support should be consistent with the level of pollution prevention activities identified in the National Program's strategic plan. Regions should be accountable for these FTEs through existing accountability systems. While the integration of pollution prevention into environmental programs is a major EPA goal, the level of resources dedicated to this effort is inadequate to produce timely results. ACTION Beginning in FY '91, the P, E & A workload model should provide a minimum of 4 FTEs per region to support "core" pollution prevention activities and pollution prevention demonstration projects in EPA and in States. Most state-based environmental management activity occurs through mechanisms of various media-specific grant programs. Currently these grant mechanisms do not recognize or include pollution 41 ------- prevention principles and/or related guidance in implementing prevention. ACTION EPA should include specific pollution prevention language and guidance in all grant-related negotiations and other activities with the States. An agencywide workgroup, including representatives from EPA Regions and HQ program offices (including GAD policy office staff.) should be established to set priorities and develop mechanisms necessary to begin to incorporate pollution prevention principles into media-specific grant programs. ffl. SUPPORT AND TRAINING ACTION ITEMS In order to gain widespread exposure and support among public and private environmental officials, pollution prevention success stories must be developed and circulated. ACTION The Pollution Prevention Newsletter has achieved considerable success in telling the pollution prevention story to a wide audience. The Pollution Prevention Division should build on this success and expand the content and readership of the newsletter. The newsletter should contain a section dedicated to regional programs, events and success stories. Reorienting the Agency toward pollution prevention will require an understanding of pollution prevention opportunities and "buy-in" by employees. Proper training is essential to achieving this reorientation. ACTION The EPA Training Institute, in association with Headquarters and Regional offices, should develop pollution prevention training curriculums which provide introductory pollution prevention orientation courses, and modules which can be incorporated into existing, program specific training courses. As pollution prevention becomes part of EPA's culture, it must be part of existing accountability and rewards structures. These elements have been critical to the success of the Regional pollution prevention programs. ACTION OHRM should develop model pollution prevention language for inclusion in the performance standards of 42 ------- senior managers by 1991 mid-year reviews. OPPE should include existing pollution prevention programs in STARS targeting and reporting requirements for FY 92. Pollution prevention programs require visible upper management support. ACTION The Administrator or Deputy Administrator should participate in the Advisory Committee process. Promoting pollution prevention through enforcement and permitting authorities is hindered by lack of understanding, disagreements about available authority, and lack of model language and conditions. ACTION A task force, including Office of General Council, the Pollution Prevention Division, National Program staff and Regions should determine the full extent of EPA's authority for pollution prevention in permitting and enforcement by April 1991. The task force should work with the Advisory Committee to insure that pollution prevention language and conditions are available throughout the Agency. Based on feedback from many States, the Agency has not been clear enough in the messages we are sending to the States in terms of why and how pollution prevention should be institutionalized into environmental management priorities. ACTION The Advisory Committee, working through National Program Managers and Regions should improve current, and establish additional, tools to assist States in strengthening their pollution prevention programs. Such tools may include: a policy statement with clear definitions; a strategy document with clearly defined roles and responsibilities for EPA HQ and Regions and the States; the National Roundtable on State Waste Reduction Programs; training programs; and other media-specific grant programs. IV. LONG TERM ACTIONS Pollution prevention can produce important environmental results in areas beyond the realm of traditional EPA programs, including energy, 43 ------- transportation and agriculture. Other federal agencies/departments have authority and policy responsibility that can affect pollution prevention in these areas. ACTION EPA must work with these other federal agencies/departments (i.e. DOD, DOE, DOI, DOT. Commerce) and the Administration to reorient them to better understand the benefits of implementing pollution prevention in their areas of responsibility. The cooperative efforts should extend beyond HQ to involve Regional Offices as well. Successful enforcement programs are an influential factor in motivating the regulated community to undertake pollution prevention. However, preventive solutions to violations often take longer to implement than command and control approaches, allowing longer periods of non-compliance. This time lag leads to conflict between aggressive enforcement and pollution prevention. ACTION A committee composed of OE, PPD, and program representatives should develop a policy that strikes a balances between the mandates of enforcement and prevention programs. Pollution prevention approaches are often inconsistent with the statutory and regulatory responsibilities of national programs and their regional counterparts. ACTION Each program should work with General Council and the Pollution Prevention Division to review their authorities and responsibilities to ensure that all pollution prevention opportunities are identified. Unnecessary barriers to pollution prevention within existing regulations should be identified, and action taken to remove them. A report for each program should be prepared by the beginning of FY92. The Agency's organizational structure, based on separate environmental laws, has produced a compartmentalized approach to environmental protection with resulting cross-media impacts. This is a significant barrier to multimedia pollution prevention efforts. ACTION The Advisory Committee should authorize and support cross-media demonstration projects to explore ways of integrating pollution prevention into our existing organizational structure. 44 ------- Appendices ------- U.S. Environmental Protection Agency National Pollution Prevention Conference July 30 - August 2, 1990 ATTENDEES Algazi, Danielle Protection Specialist U.S. EPA, Region 3 841 Chestnut St. Philadelphia, PA 19107 (215) 597-1168 Allman, Kristy PET Engineer SAIC 8400 Westpark Drive McLean, VA 22102 (703) 734-4388 Atcheson, John Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 340-3126 Bouchard, Dermont Research Chemist U.S. EPA, Region 7 726 Minnesota Ave. Kansas City, KS 66101 (913) 551-7519 Cameron, Elizabeth Pollution Prevention U.S. EPA, Region 9 75 Hawthorne St. San Francisco, CA 94105 (415) 744-2190/FTS 484-2190 Childs, Sharon Program Analyst U.S. EPA, Region 8 999 18th Street, Suite 500 Denver. CO 80202 (303) 293-1471/FTS 330-1471 Allen, Catherine Environmental Engineer U.S. EPA, Region 5 230 S. Dearborn Street Chicago, IL 60604 (312) 886-0136 Anderson, Kathleen Program Analyst U.S. EPA, Region 8 999 18th Street, Suite 500 Denver. CO 80202 (303) 293-1454/FTS 330-1454 Black. Bill Water Management Division U.S. EPA, Region 6 1445 Rose Ave. Dallas, TX 75202 (214) 655-7130/FTS 255-7130 Brodtman, Walter Office of Research & Development U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-2615 Carroll, Lynda Office of Planning & Analysis U.S. EPA, Region 6 1445 Rose Avenue Dallas, TX 75202 (214) 655-6525/FTS 255-6525 Daub, Vivian Env Protection Specialist Office of Water U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 475-6790 Appendix A 1 ------- Davenport, Thomas Regional NFS Coordinator U.S. EPA, Region 5 230 S. Dearborn Street Chicago, IL 60404 (312) 866-0209 Dick, Kevin Pollution Prevention U.S. EPA, Region 9 1235 Mission Street San Francisco, CA 94044 (415) 744-2189/FTS 484-2189 Edwards, James R Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-6920 Esher, Diana Env Planning & Assessment Sec. U.S. EPA, Region 3 841 Chestnut Street Philadelphia, PA 19107 (215) 597-1196 Flora, David RCRA State Program Sec. U.S. EPA, Region 7 726 Minnesota Avenue Kansas City, KS 66101 (913) 551-7523 Frizzell, Damon ARTX/TOPE/PPOS U.S. EPA, Region 7 726 Minnesota Avenue Kansas City, KS 66101 (913) 551-7560 Gillette, Deborah Enforcement and Permits (OWEP) U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-2656 Dholakia, Umesh Air Compliance Branch U.S. EPA, Region 2 26 Federal Place, Room 500 New York, NY 10278 (212) 264-6676 Dunaway, Georgia Risk Reduction Engineering, ORD U.S. EPA 26 W. Martin Luther King Drive Cincinnati, OH 45268 (513) 569-7650/FTS 684-7650 Elliott, Claire Environmental Engineer U.S. EPA, Region 9 75 Hawthorne St. San Francisco, CA 94105 (415) 744-1908/FTS 484-1908 Fenemore, Robert Office of Groundwater Protection U.S. EPA, Region 7 726 Minnesota Avenue Kansas City. KS 66101 (913) 551-7033/FTS 276-7033 Foecke, Terry State National Roundtable 1313 5th Street, SE Minneapolis, MN 55414 (612) 379-5995 Gangmark, Carolyn Pollution Prevention Contact U.S. EPA, Region 10 1200 6th Avenue Seattle, WA 98101 (206) 399-4072 Glass, Linda Pollution Prevention Coordinator U.S. EPA, Region 5 230 S. Dearborn Street Chicago, IL 60604 (312) 886-1019 Appendix A 2 ------- Grundahl, Nancy Environmental Planning Sec. U.S. EPA, Region 3 841 Chestnut Building Philadelphia, PA 19107 (215) 597-0355 Hazen, Susan B. Pesticides & Toxic Substances U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-3667 Hemby, James Pollution Prevention Program U.S. EPA, Region 3 841 Chestnut Building Philadelphia, PA 19130 (215) 597-8327 Keough, Paul Deputy RA U.S. EPA, Region 1 JFK Federal Building, Rm. 2203 (617) 565-3402/FTS 835-3402 Kircos, Suzanne Public Affairs Specialist U.S. EPA, Region 5 230 S. Dearborn Street Chicago, IL 60614 (312) 353-3209 Kotas, Jerry Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 245-3557 Krishnan, Bala ORD/OEETD U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-2583 Hanlon, Deborah Pollution Prevention Division U.S. EPA HQ 401 M Street. SW Washington, DC 20460 (202) 245-4164 Hefter, Richard Pesticides & Toxic Substances U.S. EPA. HQ 401 M Street, SW Washington, DC 20460 (202) 382-2892 Holtzclaw, Brian Environmental Engineer U.S. EPA, Region 4 345 Courtland St., SE Atlanta. GA 30365 (404) 347-7108/FTS 257-7108 Kern, Thomas American Management Systems 1777 N. Kent Street Arlington, VA 22209 (703) 841-5751 Koines, Arthur Office of Pollution Prevention U.S. EPA, HQ 401 M Street. SW Washington, DC 20460 (202) 382-4030 Krieger, Jackie Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 245-4172 Kulstad, Susan Planning & Analysis Section U.S. EPA, Region 1 JFK Federal Building Boston. MA 02203 (617) 565-3378/FTS 835-3378 Appendix A 3 ------- LaPosta, Dore Hydrologist U.S. EPA, Region 2 26 Federal Plaza New York, NY 10278 (212) 264-4124 Mahoney, Mark Pollution Prevention Manager U.S. EPA, Region 1 JFK Federal Building Boston, MA 02203 (617) 565-3387/FTS 835-3387 Michaels, Rowena Office of Public Affairs U.S. EPA, Region 7 726 Minnesota Ave. Kansas City, KS 66101 (913) 551-7003 Myles, Morse ORD U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 475-7161 Ondarza, Arnold Hazardous Waste Mgmt Div U.S. EPA, Region 6 1445 Ross Avenue Dallas, TX 75202 (214) 655-6770 Palmer, Kevin Chemist SAIC 8400 Westpark Drive McLean, VA 22102 (703) 821-4600 Pepino, Richard V. Environmental Assessment Br. U.S. EPA, Region 3 841 Chestnut Building Philadelphia, PA 19107 (215) 597-1182 Lewis, Nancy Planning & Analysis Section U.S. EPA, Region 1 JFK Federal Building Boston, MA 02140 (617) 565-3394/FTS 835-3394 Messner, Chris Policy Analyst SAIC 8400 Westpark Drive McLean, VA 22102 (703) 821-4808 Mitkus, Robert Water Management Division U.S. EPA, Region 3 841 Chestnut Building Philadelphia, PA 19107 (215) 597-3420 Nessmith, Thomas Chief, PPEB U.S. EPA, Region 4 534 Courtland St.. SE Atlanta, GA 30365 (404) 347-7109/FTS 257-7109 Ondich, Gregory ORD/OEETD U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-5747 Patton, Donald Chief, Policy Office U.S. EPA, Region 8 999 19th St., Suite 500 Denver, CO 80202-2405 (303) 293-1456/FTS 330-1456 Reed, Patricia Booz-Allen and Hamilton 4330 East West Highway Bethesda, MD 20814 (301) 951-2382 Appendix A 4 ------- Risler, Palma Program Analyst U.S. EPA, Region 2 26 Federal Plaza, Rm. 900 New York, NY 10278 (212) 264-7319 Roy, Manik (Nikki) OSW, OSWER Waste Minimization U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-4807 Schwartz, Amy Community Relations Coordinator U.S. EPA, Region 9 1235 Mission Street San Francisco, CA 94103 (415) 744-1171/FTS 484-1171 Sharrow, Diane Waste Minimization Staff U.S. EPA, Region 5 230 S. Dearborn Street Chicago, IL 60604 (312) 886-3730/FTS 353-4782 Simmons, Bob Senior Policy Analyst Pollution Prevention Division/HQ 999 18th St., Suite 500 Denver, CO 80202 (303) 294-7009/FTS 564-7009 Stein, Ellen Environmental Engineer U.S. EPA, Region 2 26 Federal Plaza, Rm. 1141 New York, NY 10278 (212) 264-1362/FTS 264-1362 Symmes, Brian Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 245-3590 Robertson, Lewis Environmental Engineer U.S. EPA, Region 6 1445 Ross Avenue Dallas, TX 75202-2733 (214) 655-6790/FTS 255-6790 Schilling, Hank Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-4028 Shannon, Julie Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-2736 Shaver, Elizabeth M. Pollution Prevention Program U.S. EPA, Region 4 345 Courtland St., NE Atlanta, GA 30365 (404) 347-7109/FTS 257-7109 Slotkin, Ron Technology Transfer Staff U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-7671 Swaine, Abigail Pollution Prevention Program U.S. EPA, Region 1 JFK Federal Building Boston, MA 02146 (617) 565-4523/FTS 835-4523 Teeter, David Hazardous Waste Policy Office U.S. EPA, Region 10 1200 6th Avenue Seattle, WA 98101 (206) 442-2871/FTS 399-2871 Appendix A 5 ------- Townsend, Laura Pollution Prevention Coordinator U.S. EPA, Region 6 1445 Ross Avenue Dallas, TX 75052 (214) 655-2263/FTS 255-6525 Vendinello, Lynn Pollution Prevention Division 401 M Street, SW Washington, DC 20460 (202) 382-2602 Warm, David Program Analyst U.S. EPA, Region 8 999 18th Street, Suite 500 Denver, CO 80202 (303) 293-1621/FTS 330-1621 Wehmeyer, Alan Waste Management Division U.S. EPA, Region 7 726 Minnesota Ave. Kansas City, KS 66101 (913) 551-7050/FTS 276-7050 Yoshii, Laura Dep. Director, Waste Mgmt. Div. U.S. EPA, Region 9 75 Hawthorne St. San Francisco, CA 94105 (415) 744-1730/FTS 484-1730 Tuber, Stephen Comptroller U.S. EPA, Region 8 999 18th St., Suite 500 Denver, CO 80202 (303) 293-1472/FTS 330-1472 Verdon, Tina American Management Systems 1777 N. Kent Street, 7th Floor Arlington, VA 22209 (703) 841-6212 Wasserman, Cheryl Compliance Policy & Planning 401 M Street, SW Washington, DC 20460 (202) 382-7550 Woodman, Jocelyn Pollution Prevention Division U.S. EPA, HQ 401 M Street, SW Washington, DC 20460 (202) 382-4418 Zanowick, Marie RCRA U.S. EPA, Region 8 999 18th St., Suite 500 Denver, CO 80202 (303) 293-1705/FTS 330-1705 Appendix A 6 ------- Directory of Pollution Prevention Contacts HEADQUARTERS The Office of Pollution Prevention at EPA Headquarters is responsible for all policy development, program and grants management/oversight, resource allocation, and inter-Agency/Department initiatives relating to EPA's pollution prevention program. Pollution Prevention Division FTS Number Jerry Kotas, Director Claudette Campbell, Secretary Alice Hill, AARP John Cross, Deputy Director Bob Simmons James Boland 245-3557 245-3557 245-3557 245-4164 564-7009 382-4000 Prevention Integration Branch John Atcheson, Chief 245-3575 Lenora Danger-field, Secretary 245-4164 Priscilla Flattery - Outreach, Communications, Conference, Speaking, Calendar, Newsletter 382-4023 Deborah Hanlon - Training, Awards Program, Permits 382-2726 Jim Hayes - Industry, Technical Assistance, Corporate Management Initiative 382-2689 Jim Edward - Federal Activties, Model Program 382-6920 Jocelyn Woodman - Industry Initiatives, Clearinghouse, Enforcement 382-4418 Jackie Krieger - State Grants/Legislation 245-4172 Lena Harm - State Grants/Regional Coordinator 382-2237 Policy and Innovation Branch Sharon Stahl, Acting Chief 245-4164 Yvonne Davis, Secretary 245-4164 Lynn Vendinello - Advisory Committee, Lead, Energy Issues, Policy Statement 382-2602 Brian Symmes - Grants, International, Geographies, Oil and Gas 245-3590 Dave Fege - Recycling 382-6920 Nancy Beach - List of Lists 475-7383 Julie Shannon - Strategy, Legislation 382-2736 Jim Craig - Data Collection, Analysis/Data, Targeting 245-4168 David Bassett - Clean Air, Energy, Transportation Issues 245-4167 Appendix B 1 ------- Office of Pesticides and Toxic Substances FTS Number Susan Hazen 382-3667 Richard Hefter 382-2892 Office of Water Vivian Daub - Water Policy Office 475-6790 Deborah Gillette - Enforcement and Permits 382-2656 Office of Research and Development Morse Myles - Clearinghouse 475-7161 Gregory Ondich 382-5747 Office of Enforcement Cheryl Wasserman 382-7550 REGIONS The ten EPA Regions serve as the front line in implementing EPA's pollution prevention program within their respective States. Region I AbbySwaine 835-4523 Susan Kulstad 835-3378 Mark Mahoney 835-3387 Region II Palma Risler 264-7319 Region III Nancy Grundahl 597-0355 James Hemby 597-8327 Region IV Betsy Shaver 257-7109 Appendix B 2 ------- Region V Linda Glass Region VI Lynda Carroll Region VII Alan Wehmeyer Chet McLaughlin David Flora Region VIII Don Patton Sharon Childs Region IX Laura Yoshii Kevin Dick Liz Cameron Region X David Teeter Claire Rowlett FTS Number 886-1019 255-6525 276-7050 276-7666 276-7523 330-1456 330-1471 484-1730 484-2189 484-2190 399-2871 399-1099 Appendix B 3 ------- Draft Pollution Prevention Policy Statement - January 26, 1989 I. Background EPA has made substantial progress over the last 18 years in improving the quality of the environment through implementation of media- specific pollution control programs. Not withstanding past progress, there are economic, technological, and institutional limits on how much improvement can be achieved under these programs, which emphasize management after pollutants have been generated. As early as 1976, EPA believed the nation could not continue to reduce threats to human health and the environment while utilizing only better methods of control, treatment, or disposal. In practice, waste management activities by both the regulatory and the regulated community have largely focused on treatment, control and disposal as specified in EPA's major statutes and to a lesser extent on recycling. Although each of these techniques is appropriate in a comprehensive waste management strategy, government and industry are beginning to realize that end-of-pipe pollution controls alone are not enough. Significant amounts of waste containing toxic constituents continue to be released into the air, land, and water despite stricter pollution controls and skyrocketing waste management costs. There is increasing evidence of the economic and environmental benefits to be realized by reducing waste at the source rather than managing such waste after it is produced. Elimination of tons of pollutant discharges can be combined with cost savings estimated from the cost of pollution control facilities that did not have to be built; reduced operating costs for pollution control facilities; reduced manufacturing costs; and retained sales of products that might otherwise have been taken off the market as environmentally unacceptable. Today's policy statement commits EPA to a program that reduces all environmentally harmful releases. EPA's experience with its current programs has shown that, notwithstanding the substantial gains that have been made in limiting environmental pollution, media-specific programs have some inherent limitations. Efforts to control or treat pollutants subsequent to their generation or production can sometimes result in transferes of these pollutants from one environmental medium to another, where they may continue to present a hazard. In addition, once these pollutants have been produced or generated, some proportion of those releases will have an impact on the environment, however effective the control or management techniques. The preventive approach of today's policy statement provides a way to more effectively respond to these remaining problems. Appendix C 1 ------- EPA believes that all sectors of our society must work together to ensure continued environmental protection. EPA is committed to working with individuals and organizations (both public and private) to make source reduction and as a second preference, environmentally sound recycling the major focus of future environmental protection strategies. In particular, EPA believes that State and local governments must play a primary role in encouraging this shift in the environmental priorities of all sectors of industry and the public. Some programs within EPA have already adopted measures to promote source reduction and recycling. For example, the Office of Water has adopted effluent guidelines that have resulted in flow reductions and product substitutions. The rapid phasing down of lead in gasoline by EPA's Office of Air and Radiation Programs is another attempt to reduce pollution at the source. Nevertheless, much of the past focus in these programs has been on pollution control rather than pollution prevention. It is necessary at this time to reassess EPA's programs in light of today's policy statement and redirect them accordingly. The term "waste minimization" which EPA has previously used in reference to source reduction and recycling activities in its hazardous waste program, has been replace in today's policy statement by the phrase "pollution prevention." Through eliminating a term that may be perceived as closely tied to RCRA, EPA is emphasizing that the policy has applicability beyond the RCRA hazardous waste context. EPA stresses that the policy focuses primarily on the prevention of pollution through the multi-media reduction of pollutants at the source. In addition, in order to obtain additional benefits of avoiding releases to the environment, EPA's pollution prevention program secondarily promotes environmentally sound recycling. tt EPA's Pollution Prevention Policy EPA's proposed policy encourages organization, facilities and individuals to fully utilize source reduction techniques in order to reduce risk to public health, safety, welfare and the environment as a second preference to use environmentally sound recycling to achieve these same goals. Industrial source reduction can be accomplished through input substitution, process modification, improved houskeeping, and on-site closed loop recycling. Although source reduction is preferred to other management practices, the Agency recognizes the value of environmentally sound recycling, and is committed to promoting recycling as a second preference, above treatment, control and disposal. EPA believes pollution prevention through source reduction and environmentally sound recycling is highly desirable, and that as a Nation there are many opportunities in source reduction and recyling that we have not yet pursued. However, we recognize that, while Appendix C 2 ------- there is still much progress to be gained, the extent to which we can prevent pollution also has limitations and that safe treatment, storage and disposal for pollution that couldn't reasonably be reduced at the source or recycled will continue to be important components of an environmental protection strategy. Source reduction and recycling will not totally obviate the need for or the importance of these processes. Individuals as well as industrial facilities or organizations can practice source reduction and recycling through changing their consumption or disposal habits, their driving patterns and their on- the-job practices. EPA believes that developing and implementing a new multi-media prevention strategy, focused primarily on source reduction and secondarily on environmentally sound recycling, offers enormous promise for improvements in human health protection and environmental quality and significant economic benefits. HL Development of EPA's Multi-Media Pollution Prevention Program EPA has initiated developpment of a comprehensive pollution prevention program to implement this pollution prevention policy throughout the Agency programs, whether they affect air, land, surface water, or ground water. EPA has established a Pollution Prevention Office which together with the Agency's media-specific offices will develop and implement this program. EPA will develop an overall Agency pollution prevention strategy, as well as coordinate strategies among EPA's program and regional offices. An important emphasis of these strategies will be on educational, technical assistance and funding support to make it easier to build these programs into the public and private sectors. An Advisory Committee of senior Agency managers will help direct EPA's pollution prevention program and will assure the participation of the entire Agency in this important mission. As part of this program, EPA will establish mechanisms for avoiding or mitigating the generation and cross-media pollution prevention program will focus on several key components. These include: The development of institutional structures within each of EPA's media-specific and regional offices to ensure that the pollution prevention philosophy is incorporated into every feasible aspect of internal EPA decisionmaking and planning; The support of State and local pollution prevention programs. EPA believes that State and local agencies are more aware of the problems facing the commercial or manufacturing industries or consumers, than the federal government. Indeed, a few States have already formally recognized the importance of multi-media pollution prevention. One of EPA's primary goals is to help States develop their own pollution prevention programs; Appendix C 3 ------- The development of an outreach program targeted at State and local governments, industry and consumers, designed to effect a cultural change emphasizing the opportunities and benefits of pollution prevention; The creation of incentives and elimination of barriers to pollution prevention; The development of a multi-media clearinghouse to provide education and technical information. This includes the support of research, development and demonstrations necessary to provide relevant data; and The collection, dissemination and analysis of data for the purpose of evaluating national progress in multi-media pollution prevention. EPA believes that the development of a comprehensive multi-media pollution prevention, policy offers enormous promise for improvements in human health protection and environmental quality. Because the focus of pollution prevention is on greater efficiency in the use of materials and processing of products, its implementation could additionally result in significant economic benefits. There are significant opportunities for industry to reduce the generation of waste at the source through cost-effective changes in production, operation and raw materials use. Such changes offer industry substantial savings in reduced raw material, waste management and liability costs as well as help protect the environment. There are varying views among representatives of industry, public interest groups, state and local governments and others over the role of recycling in pollution prevention. Thes Agency believes that source reduction (including closed-loop recycling) can reduce risk and should be implemented in a cost-efficient manner. It is generally preferred over other management approaches. The Agency also believes that out-of-loop and off-site recycling, when properly conducted, also offers the potentional for significant economic benefits and reduced risk. With the publication of this proposed pollution policy, the Agency would like to specifically request comment on the role of environmentally sound recycling in the pollution prevention program. Other comments on this policy, and on the steps necessary to implement it effectively are invited. Appendix C 4 ------- xvEPA United States Environmental Protection Agency Office of Pollution Prevention Washington, DC 20460 Summer 1990 Pollution Prevention Fact Sheet Setting Up a Pollution Prevention Program Where Do I Start? Program Elements Industry, service businesses, municipalities, and other institutions are finding that pollution prevention programs can result in improved regulatory compliance, reduced costs for pollution control and waste disposal, improved employee safety, and reduced liability associated with the management of hazardous materials and wastes. In other words, a pollution prevention program is economically as well as ecologically sound, and can be implemented by any organization. A Pollution Prevention Program is defined as an organized, comprehensive, and continual effort to systematically reduce or eliminate pollution and wastes. In June 1989, EPA published Draft Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program to assist hazardous waste generators in complying with RCRA certification requirements. The elements outlined in the guidance can also be used in the development of a pollution prevention program: (1) Top management support is needed to ensure that pollution prevention becomes an organizational goal. To demonstrate such management support, use techniques such as: ~ Written company policy on pollution prevention Specific goals and objectives for reducing waste stream volume or toxicity Designating program coordinators - Publicizing and rewarding successes Employee training. (2) Identify and characterize wastes and pollutants -- in terms of the source of generation, why each waste is produced, the type and quantity generated,, its toxicity, and all possible routes of exposure. Appendix D 1 Printed on-Recycled Paper ------- This will help in prioritizing prevention efforts and identifying key personnel that can assist in implementing the program. (3) Periodic pollution prevention assessments or environmental audits help to ensure that pollution prevention opportunities continue to be sought and solutions implemented. (4) A cost allocation system. Departments and managers should be charged "fully-loaded" pollution control and waste management costs. Labor costs, liability, regulatory compliance, disposal and oversight costs should all be included. (5) Encouragement of technology transfer. Many successful techniques have been documented that may be applicable to your facility. Information can be obtained from federal and state agencies, universities, trade associations, and other firms. (6) Program evaluation. Conduct periodic reviews of program effectiveness to provide feedback and identify potential areas for improvement. Has the pollution prevention ethic become a significant part of the way you do business? Have all opportunities to prevent pollution been explored? Where Do A useful, ongoing source of information is EPA's Pollution I Go Next? Prevention Information Clearinghouse (PPIC), which offers a computerized network for information exchange, a hotline, and a document repository. To reach the Clearinghouse, write: PPIC, Science Applications International Corp., 8400 Westpark Drive, McLean, VA 22102, or call: 1-800-424-9346 (or 202-382-3000 in the Washington, D.C. area). Another next step would be to consult a manual for conducting pollution prevention assessments. Such manuals include: EPA Waste Minimization Opportunity Assessment Manual. EPA/625/7-88/003. July 1988. Hazardous Waste Engineering Research Laboratory, U.S. EPA, 26 W. Martin Luther King Drive, Cincinnati, OH 45268. New York State Waste Reduction Guidance Manual March 1989. New York State Department of Environmental Conservation, Division of Hazardous Substances Regulation, 50 Wolf Road, Albany, NY 12233-7253. Profiting from Waste Reduction in Your Small Business. 1988. Alaska Health Project, 431 West 7th Ave., Suite 101, Anchorage, AK 99501, 907-276-2864. Waste Minimization: Manufacturers' Strategies for Success. 1989. National Association of Manufacturers, 1331 Pennsylvania Ave. NW, Suite 1500, Washington, D.C. 20004-1703. S19.95 NAM Mcmbers/S29.95 Non-Members. A Citizen's Guide to Promoting Toxic Waste Reduction. 1990. INFORM, 381 Park Ave. S. New York, NY 10016. S15.00 plus S2.50 shipping. Appendix D 2 ------- United States Environmental Protection Agency Office of Pollution Prevention Washington, DC 20460 Summer 1990 &EPA Pollution Prevention Fact Sheet EPA's Pollution Prevention Incentives for States Goals 1988/89 Awards 1989/90 Awards States have been at the forefront of the pollution prevention movement, providing a direct link to industry, local governments, and consumers. Through grants to states, EPA aims to enhance state capabilities to demonstrate innovative and results-oriented programs and to assist states in implementing a multimedia prevention approach. In fiscal year 1988, EPA's Office of Pollution Prevention awarded over $3.9 million in multi-media state grants to 13 states and one regional association of waste management officials. Awards ranged from $197,000 to S300,000 over a two to three year period. Grant recipients include Alaska, Idaho, Indiana, Kentucky, Louisiana, Massachusetts, Michigan, Mississippi, New Jersey, New York, North Carolina, Rhode Island, Texas, and the New England Waste Management Officials Association. (See inside for details.) A second round of grants was awarded in May 1990 totalling $7 million; 25 state-based initiatives have been funded to further pollution prevention efforts across the country. Projects are being funded in all 10 EPA regions, in the following locations: California, Colorado, District of Columbia, Delaware, Georgia, Iowa (2), Illinois, Indiana, Massachusetts, Maine, Michigan (2), Minnesota, Missouri, Nebraska, New Jersey, New York, Oklahoma, Pennsylvania, Tennessee, Virginia, "Washington, West Virginia, and American Samoa. The awards range from 5125,000 to 5300,000 for projects lasting up to three years. States are required to contribute at least 10 percent of the total cost of each project in their jurisdiction. (See inside for details.) Appendix D 3 Printed on Recycled Paper ------- 1988/89 Awardees ALASKA Department of Environmental Protection/ Alaska Health Project IDAHO Department of Health & Welfare/Division of Environmental Quality INDIANA Dept. of Environmental Management KENTUCKY Dept. of Environmental Protection LOUISIANA Dept. of Environmental Quality MASSACHUSETTS Dept. of Environmental Management MICHIGAN Department of Natural Resources MISSISSIPPI Department of Natural Resources NEWMOA (New England Waste Management Officials Association) NEW JERSEY Hazardous Waste Facilities Siting Commission NEW YORK Department of Environmental Conservation NORTH CAROLINA Dept. of Natural Resources & Community Development RHODE ISLAND Dept. of Environmental Management TEXAS Water Commission/ Hazardous & Solid Waste Division Two-year effort to establish an integrated prevention program, including tech transfer/assistance, audits, curriculum development, pilot waste reduction programs for rural Alaska. Two-year program to establish state-sponsored, county- managed recycling program for industrial wastes; establish waste exchange service. Three-year program to create an integrated technical assistance and enforcement program. Three-year program to compile a single, cross-media risk and release database, expand waste minimization programs, pursue other cooperative projects. Research to define state problems, target Industries, and establish performance measures (3 year program). Grant to expand existing technical assistance. Pilot project includes training for interns, state inspectors; workshops; financial feasibility model for company managers. (3 yrs.) Three-year "Source Reduction Intern Program;" focus will be on small/medium sized electroplaters, automobile assembly and component part plants. Two-year program offering outreach, tech assistance, demonstrations to small/medium sized industries. Regional project to establish centralized clearinghouse & database, provide tech assistance to states, and develop source reduction options for wastestreams destined for resource recovery systems. Two-year tech assistance program, including methods development research for targeting priority industries and development of PC software for tracking raw products, waste generation, and waste management costs. Three-year program to hire additional staff, provide training, conduct workshops, establish clearinghouse, etc,, with aim of reducing waste discharges. Two-year effort to augment current extensive program with waste reduction information management system, to serve as demonstration project for other states. Technical assistance program including in-plant audits, re-audits, documentation of case studies, training {3 yrs). Development & implementation of Waste Minimization Recycling Program (2 years, 9 months). Appendix D 4 ------- 1989/90 Awardees AMERICAN SAMOA Environmental Protection Agency CALIFORNIA Department of Health Services COLORADO Department of Health DELAWARE Dept. of Natural Resources & Environmental Control D.C; Metropolitan Washington Council of Governments/Dept. of Environmental Programs GEORGIA Department of Natural Resources ILLINOIS Environmental Protection Agency INDIANA: Purdue University, Division of Sponsored Programs IOWA Department of Natural Resources IOWA Waste Reduction Center MAINE: Univ. of Maine, Dept. of Chemical Engineering MASSACHUSETTS Dept. of Environmental Protection MICHIGAN Department of Education MICHIGAN State University, Cooperative Extension Service MINNESOTA Office of Waste Management Project to promote public awareness of proper waste disposal practices, promote aluminum can recycling, conduct waste oil demonstration project (3 years). Two-year interagency effort to develop a comprehensive training program to promote pollution prevention. Two-year project with educational, data-gathering, training components; examination of urban development, land use, transportation issues. Two-year effort to develop and implement Pollution Prevention Program, overseen by Advisory Committee. Public/private partnership to prevent pollution from vehicle emissions, demonstrate impacts of using alternative fuels in buses (3 years). One-year project to establish multi-media source reduction and recycling program, provide training tech assistance. One-year project to implement Toxic Pollution Prevention Act, including targeting prevention opportunities, sponsoring pilot projects, reviewing facility plans. Three-year effort focusing on point source agricultural pollution prevention, to include training for Extension Service agents, an inventory of current practices and technologies, an Advisory Council, and possible establishment of farm chemical "clean-up days." Three-year project focusing on large quantity generators, including Governor's Award program, procurement directives, retired engineer program, incentive grants. Three-year program for small quantity generators, providing technical assistance, expanded information base. Three-year educational program for groups dealing with the public or students. Assistance to ongoing projects including cross-media permitting, inspection, enforcement, and data-gathering; developing regulatory toxics use reduction planning requirements (2 years). Project focusing on multi-media pollution prevention at educational facilities (1 year, 9 months). Development of 100-hour course for waste assessors (Michigan Waste Assessment Training Project) (U years). Development and evaluation of risk screening and priority ranking method for hazardous air emissions (2 years). Appendix D 5 ------- 1989/90 Awardees (continued) MISSOURI Department of Natural Resources NEBRASKA: University of Nebraska - Lincoln NEW JERSEY Department of Environmental Protection NEW YORK: Western NY Economic Development Corp./Erie County Dept. of Environment & Planning OKLAHOMA Department of Health PENNSYLVANIA Center for Hazardous Materials Research TENNESSEE Department of Health and Environment VIRGINIA Department of Waste Management WASHINGTON Department of Ecology WEST VIRGINIA Division of Natural Resources Three-year effort focusing on point source agricultural pollutants, with demonstration projects at bulk fertilizer and pesticide dealerships. Three-year program to assess waste streams associated with specific commercial establishments in rural areas, develop pollution prevention office. Expansion of Office of Pollution Prevention to coordinate existing activities and target industries; development of guidance package for preparing prevention plans (3 years). Expansion of existing Erie County Prevention Program to incorporate multi-media pollution prevention policy and serve as a model to other counties (3 years). Three-year funding to support coordination of prevention activities, education, technical assistance, consideration of economic incentives. Model prevention program in university operations; expansion of existing activities to targeted industries including fabricated metal, machinery, printed circuit board manufacturers, and chemical products (2 years). One-year project to include training of retired engineers, teleconferencing and videos, industry-specific education programs, and workshops for regulatory personnel Two-year program to form interagency team of "internal champions" to promote multi-media prevention and identify industrial opportunities for prevention (2 years). Two-year project to obtain baseline data for measuring waste reduction and recycling, and to increase coordination on pollution prevention programs and issues. Public-private partnership to facilitate voluntary state- wide program modelled after N1CS' "Scorecard" reporting system for chemical producers and processors (3 years). For Further Information For further information on the multi-media grants program, contact Jackie Krieger in EPA's Office of Pollution Prevention, (202) 245- 4164. Appendix D 6 ------- v^EPA United States Environmental Protection Agency Office of Pollution Prevention Washington, DC 20460 Summer 1990 Pollution Prevention Fact Sheet Pollution Prevention Training and Education Resource Guide Video Newsletter An important goal of EPA's Pollution Prevention Program is to ensure that pollution prevention training and education are available to government, industry, academic institutions, and the general public. Training and education are needed to help institutionalize prevention as the' strategy of choice in ail environmental decision-maJdng and protection activities. EPA's Office of Pollution Prevention has developed a resource guide, Pollution Prevention Training Opportunities in 1990. The guide describes the types of training courses, workshops, and seminars being offered in each state and provides contact names and-addresses. Other sections of the guide list available instruction manuals, opportunity assessment materials, fact sheets, videos, and state and EPA contacts on pollution prevention. Copies of the guide may be obtained through the Pollution Prevention Information Clearinghouse, SAIC, 8400 Westpark Drive, McLean, VA 22102, Tel: 1-800-424-9346 (or 202-382-3000 in the Washington, D.C. area). EPA's 30-minute documentary on pollution prevention is intended to raise awareness of pollution problems and solutions. The video highlights case studies of successful pollution prevention programs. Available, along with other videos, through the Pollution Prevention Information Clearinghouse. Pollution Prevention News contains articles and editorials on pollution prevention topics, reports on EPA activities related to pollution prevention, information on new technologies and approaches, a calendar of events, and special features on people and places in the news. To be placed on the mailing list, write: Pollution Prevention News, U.S. EPA, 401 M Street SW (PM-219), Washington, DC 20460. Appendix D -i Printed on Recycled Paper ------- Conferences EPA cosponsors pollution prevention conferences and workshops throughout the year with trade and other professional associations and states. Conferences are listed in the Calendar section of Pollution Prevention News and in the Pollution Prevention Information Exchange System (PIES) of the Pollution Prevention Information Clearinghouse. (For more information on PIES, call the PPIC Technical Support line at 703-821-4800.) Courses The Office of Pollution Prevention is developing specialized courses designed for government employees and industry. The courses will be available through the EPA Regional Offices starting in 1991. Course topics will include: - Pollution Prevention Orientation Pollution Prevention for Permit Writers Industrial Waste Pollution Prevention for Inspectors. Pollution Prevention for Regulation-Writers Speakers' Bureau The Office of Pollution Prevention is developing a speakers' bureau to assist in pollution prevention training and technical assistance for government and industry groups. For More Information For more information, call the Office of Pollution Prevention Training Coordinator at 202-245-4164. Appendix D ------- U.S. EPA Pollution Prevention Information Clearinghouse (PPIC) In order to promote pollution prevention. EPA has established the Pollution Prevention Information Clearinghouse (PPIC). a clearinghouse dedicated to reducing industrial pollutants through technical information transfer, education, and public awareness. The PPIC contains technical, policy, programmatic, legislative, and financial information and works through four information exchange mechanisms: Repository -- A hard copy reference library containing the most up-to-date information on pollution prevention. PIES A computerized national and international network accessible to anyone with a personal computer (PC) and modem. PIES provides a forum for exchange of questions and ideas and contains pollution prevention data bases and document ordering functions. Hotline ~ A free telephone service to answer questions, make referrals, and provide a link to PIES for users without access to a PC. RCRA/Superfund Hotline 800/424-9346 Small Business Ombudsman Hotline 800/368-5888 PPIC Technical Assistance 703/821-4800 Outreach Efforts ~ Information packets containing general and industry-specific materials on prevention opportunities and workshop training sessions. Through PPIC, individuals in Federal, State, and local government; industry; academia; public/private institutes; and public interest groups can access the latest pollution prevention technology and program developments. For more information on any aspect of the PPIC, call: Myles E. Morse, Office of Environmental Engineering and Technology Demonstration (202) 475-7161; FTS 475-7161, or Priscilla Flattery. Pollution Prevention Office, (202) 245-3557; FTS 245-3557. Appendix E 1 ------- |